Pangan v. Ramos
REITERATIONFacts
The Antecedents: Complainant Santa Pangan sought to cite respondent Atty. Dionisio Ramos for contempt. The basis for the contempt charge stemmed from respondent's motions for postponement of hearings in an administrative case. These motions were predicated on respondent's alleged prior engagements in Branch VII, Court of First Instance of Manila, in Criminal Case No. 35906, People v. Marieta M. Isip. Respondent claimed he had a case set for hearing on those dates under the name "Pedro D.D. Ramos." Procedural History: The administrative case proceeded with hearings, during which respondent filed motions for postponement. Upon verification, the attorney of record for the accused in Criminal Case No. 35906 was found to be "Atty. Pedro D.D. Ramos." Respondent admitted using this name but asserted a right to do so, citing his birth certificate which listed his name as "Pedro Dionisio Ramos," with "D.D." being an abbreviation of "Dionisio Dayaw" and his maternal surname. The Petition: The complainant filed a motion to cite respondent Atty. Dionisio Ramos for contempt for allegedly misrepresenting himself to the court by using the name "Pedro D.D. Ramos" instead of his registered name, "Dionisio D. Ramos," which caused delays in the administrative proceedings.
Issue(s)
Whether respondent Atty. Dionisio Ramos committed a violation of his attorney's oath and the rules of professional conduct by using the name "Pedro D.D. Ramos" instead of his registered name "Dionisio D. Ramos" in court proceedings. Whether such act warrants a finding of contempt against the respondent.
Ruling
The Supreme Court found the respondent's explanation untenable and held that he violated his solemn oath as an attorney. The Court reprimanded the respondent and warned him that repetition of the act could lead to suspension or disbarment. The Court also directed the Investigator to proceed with the hearing of the administrative case to terminate it promptly.
Ratio Decidendi
On Whether respondent Atty. Dionisio Ramos committed a violation of his attorney's oath and the rules of professional conduct by using the name "Pedro D.D. Ramos" instead of his registered name "Dionisio D. Ramos" in court proceedings: The Court held that the respondent's explanation was untenable. The name appearing in the Roll of Attorneys is "Dionisio D. Ramos." The attorney's roll is the official record of those authorized to practice law, and a lawyer is not permitted to use a name other than the one inscribed therein. The solemn oath taken by an attorney obliges them to "do no falsehood" and to uphold the principles of truthfulness, candor, and frankness. By representing himself as "Pedro D.D. Ramos" instead of "Dionisio D. Ramos," the respondent engaged in deception and violated his oath. The Court emphasized that an attorney's duty to the court is to employ means consistent with truth and honor, and their high vocation is to correctly inform the court upon the law and facts, aiding it in rendering justice. Resorting to deception violates this oath. The Court found that the respondent's use of "Pedro D.D. Ramos" before the courts, instead of his authorized name, constituted deception and demonstrated a lack of candor in dealing with the courts. On Whether such act warrants a finding of contempt against the respondent: While the respondent's actions constituted a violation of his oath and professional duties, the Court, in this instance, chose to impose a reprimand rather than contempt. The Court noted that this was the respondent's first such aberration, which precluded the imposition of a more severe penalty. However, the resolution clearly indicates that the act itself was a serious breach of professional conduct. The complainant's motion was to cite the respondent for contempt, and the Court's resolution addresses the underlying conduct that would typically be grounds for such a finding, even if the specific penalty imposed was a reprimand and warning. The Court's directive for the Investigator to proceed with the hearing suggests that the administrative case itself, which could potentially lead to further sanctions, would continue.
Main Doctrine
A lawyer must practice law using the name inscribed in the Roll of Attorneys. Using a different name, even if it is a variation or includes other given names, constitutes a violation of the lawyer's oath to do no falsehood and violates the duty of candor and frankness owed to the court. The Roll of Attorneys is the official record of authorized practitioners, and adherence to it is paramount for maintaining the integrity of the legal profession and the administration of justice.